CDC/RAC Deterministic Model

Model was developed to estimate radon levels
outside the Fernald plant site

Model was based on physical and mathematical
principles, such as emission rates from K-65 silos,
plume dispersion from a point source, meteorological
conditions, and engineering controls

Data were only used to calibrate the model

Output of model was 24-hr average exposures to
residents within 10-km radius of K-65 silos




CR-39 Assay

© Decided to use CR-39 assay to validate
estimates from mathematical deterministic
model.

© Asked NIOSH for funding

C Pilot study — 20 samples

© Main study — 80 samples

© Additional study — another 31 samples

© 131 CR-39 plastics were placed on both
inside and outside of glass panes in buildings
throughout the plant.


Wage eee

oS

Se





oe

Summary

Deterministic model for. K-65 source agrees reasonably well with
the 1991 radon measurements (validation study using Carderelli
data)

CR-39 assays indicate a source of radon other than K-65,
probably Q-11 silos, stored raffinate, local processing activities

Final estimates assign high radon exposures to workers in the
plant 2/3 area who were employed from:1952 to 1958

The final product of this study is a matrix of radon exposures for
each Fernald worker by year

Exposures may be used in a future epi study or for
compensation purposes under a current DOL / NIOSH program


Work Location Assignment

We developed a series of assumptions regarding
work locations for combinations of plant,
department and job title, using records such as
FWMMP occupational history questionnaire and
interview information, union contracts, and
position descriptions.

Each record of the worker’s job history was then
assigned a location code, indicating one or
several work locations for that time period.


Analysis of CR-39 Data

© Po-210 measures were linked to lat/long coordinates
of the building

© Weighted multiple regression model was used to
estimate Po-210 levels for each building where
workers were assigned

C Weights were a function of wind speed and direction
from Q-11 silos as the point source

© Other factors included in the model were building
construction year and inside/outside location of film


STUDY OBJECTIVE: Estimate annual and cumulative
exposures to radon decay products among workers employed at
Fernald site from 1952 to 1988.

STUDY METHODS (at beginning of study):

Use deterministic mathematical model developed for the CDC
dose reconstruction project to estimate radon levels across the
site, arising from the K-65 silos.

Investigate and estimate radon exposures from secondary
sources using CR-39 assay of window glass.

* Assign locations of workers; assign a set of shift probabilities to
workers.

Assign estimated annual radon levels measured in Working
Levels (WL) to workers by their shift and working location in
each year of employment.


| Percent Working Each Shift (Self-Reported)
by Standardized Job Title Clusters A-G

120

100

&0 @ Day Shift
Eve Shilt
5 1G Night Shift
| 5 oF O Rotating
a

20

fet. |

0 5 a
Admin/Cler Technicians ChemOp Amaysday- SupportSery Foremen Technogolist;
data Research

Tech

Cluster of Standardized Job Titles


teen nny

» Since radon exposure resulted in dispersion of
radon gas from a source, location of workers was
a key parameter in exposure estimation

« 7143 persons ever worked at the site

« 2158 were participants of the Fernald Worker
Medical Monitoring Program, from whom we have
collected detailed occupational history
information (questionnaires and interviews)


Work Location Code — linked to multiple
exposure estimate locations

—~-— aor ee}

ees =}

“Single location” code - Plant 2/3
" 66% Building 2A — Ore Refinery Plant
* 10% Building 2D- Metal dissolver building

* 7% each Buildings 3C, 3E and 3H — Control Tower, Hot
Raffinate Building, Refinery Sump

* 3% Building 39A — incinerator Building

Combination code - ANDBLDG15,P
* 60% Building 15a - Laboratory

« 40% P [Production Area]— many buildings in the
production area


__ Location Assignment Method

oo =
om)

* Obtained file of job history (multiple record per
person file) from NIOSH- each record contained
Plant, Department and Job Title information for
periods of employment, with beginning and end

ates.

© For some workers, no work location could be
inferred from information in personnel records:

» Mechanical Division (electricians, carpenters,
machinists, etc.)

« Laboratory Division

« Inventory and time clerks who worked in
offices in the production plants, and

* Workers in the Security division


~ CR-39 is a plastic film taped to window glass for about 3 weeks
in buildings on site to record polonium-210 alpha activity, a
primary radon decay product.

| CR-39 Assay

© Glass in place throughout the plant history serves as a
cumulative radon dosimeter.

© CR-39 assay was developed at the University of Bristo! and
used in case-control studies of lung cancer and radon in homes
but never in an industrial, highly contaminated setting.

’




Health Effects of Radon

= oo )

» When radon progeny are inhaled and release
alpha particles within the lungs, the cells lining
the airways receive genetic damage, and
ultimately lung cancer may result.

« Combined risk of smoking and radon — more than
additive, less than multiplicative.

« Radon also know to increase risk of cataracts


Percent Working Each Shift (Self-Reported) by Standardized Jobtitle Clusters H-O

120.0

Eve Shit,
1 Night Shiny
| Rotating

Percent
8
3S

40.0

20.0

0.0 4

Prod-Not Chem Inspector ‘Mil Man Clerk Laborer Maintence trade; Machinist
Op Mechanic.


PROD or P }Production plants|

PA [Production Areal includes additional buildings
bordering the production plants, representing the
“controlled” area,

NC {Non-Contralled area} includes non-production
buildings.

ALL includes every location on the site and is enclosed
within the black box.

Map of Areas in Overall Area Codes
(Prod, PA, NC, NC+P, All)

|



K-65 Silo - 2003





CDC Fernald Dosimetry Reconstruction

Radon Release Estimates

Period Median Estimate
1952-1953 K-65 Silos 1900 Ci
Drummed waste 720 Ci
1953-1958 K-65 Silos 4900 Cil/yr
1959-1979 K-65 Silos 6200 Ci/yr
1980-1987 K-65 Silos 940 Ci/yr
1988 K-65 Silos 230 Ci



Uranium Decay Chain

Isotope Half-life Radiation
Uranium-238 4,500,000,000 years alpha
Thorium-234 24 days beta, gamma
Protactinium-234m 1.2 minutes beta, gamma
Uranium-234 250,000 years alpha, gamma
Thorium-230 80,000 years alpha, gamma
Radium-226 4,622 years alpha, gamma
- Radon-222 3.8 days alpha
Polonium-218 3.05 minutes alpha
Lead-214 26.8 minutes beta, gamma
Astatine-218 2.0 seconds alpha
Bismuth-214 19.7 minutes i beta, gamma
Polonium-214 0.000164 seconds alpha, gamma
Thallium-210 1.3 minutes beta, gamma
Lead-210 22 years | beta, gamma
Bismuth-210 5.0 days ] beta
Polonium-210 138 days alpha, gamma
Thallium-206 4.2 minutes beta
Lead-206 Stable none



Worker Assigned to a Specific Building

ID: 34076

Hire Date Term Date

11/7/1954 01/17/1957

Date Plant Dept Job Title Location

Code Code :
eerste arora wststerninrntenent
M1M7/1954 2 Prod Laborer Plant 2/3
09/26/1955 3 Prod Chemical Operator Plant 2/3
Helper

04/02/1956 3 Prod Chemical Operator Plant 2/3
11/09/1956 3 Prod Laborer Plant 2/3


WAITE, SCHNEIDER, BAYLESS & CHESLEY Co., L.P.A.

ATTORNEYS & COUNSELLORS AT LAW

1513 Fourtu & Vine ToweR
ONE WesT Fount Srreer
CINCINNATI, Onto 45202
TELEPHONE (513) 621-0267

Fax (513) 381-2375
Fax (513) 621-0262

August 22, 2006 SEC £6

Laurie Ishak

SEC Petition
NIOSH-OCAS

4676 Columbia Parkway
Maiistop MS-C47
Cincinnati, OH 45226

In re: Special Exposure Cohort Employees’ Application for Fernald, Ohio
Dear Ms. Ishak:

We are writing this letter pursuant to 42 C.F.R. 83. We wish to bring to your attention an
issue to be considered in your evaluation of the Special Exposure Cohort Employees’
Application for the workers at Fernald, Ohio. filed the application.

Susan Pinney, an epidemiologist at the University of Cincinnati, received a NIOSH grant
to study the radon doses that Femald workers received from Q-11 and K-65. Ata recent
Radiation and Health meeting in California, Dr. Pinney presented the radon exposure estimates
for the Fernald workers. Jim Neton and Doug Daniels, both representatives of NIOSH, attended
the presentation and authorized Dr. Pinney to provide the radon findings to the workers. We are
enclosing a copy of the slides that Dr. Pinney prepared and gave to us.

What these slides document is that Fernald workers have had exposures to radon from the
early 1950s to the present time. While Dr. Pinney’s study stops in 1989, the worker exposures
have continued because the potential of harm from K-65 residual material is still present at
Fernald. The SEC petition should include the entire workforce.

Although we have never had an opportunity to review the Fernald workers’ dose
calculations being used for determination of EEIOCPA awards, it is our understanding that the
radon doses from Q-11 and K-65 have not been included. Further, these radon doses make
calculation of an accurate dose almost impossible because no contemporaneous exposure records
for workers exist. This study provides a technical basis for concluding that an upper bounds
cannot be established for radon exposure.



Mean and Highest Yearly Worker Radon Exposure Estimates (WLM)
due to K-65 source

“——

ay
FEF EEF EHS

S OS ab ak AO Ad
SEF ELE EL S

w7
g es

1a,

Year




Sources of Radon at Fernald

(At time of grant proposal)

Ju

« K-65 Silos — held raffinate from processing
ores rich in uranium, which contained
radium

« Radium bearing residues from Mallinckrodt
Chemical Works and other DOE sites

* Approximately 25,000 barrels — into Silo 1

« Processing of pitchblende ores at FMPC
« During 1950’s ~ residues into Silo 2





Work Shift — Assumption
_ Development

Specific questions on work shift included in
FWMMP questionnaire modules

© Compiled responses of workers who completed
questionnaires

© Used these data to develop assumptions about
probability of working evening or night shift for
each Jobtitle


WiM

160

Mean and Highest Yearly Worker Radon Exposure Estimate (WLM)
due to Q-11 source

140 +-

120 7—

400

80

60

40



Person-years at Each Exposure Estimate Location 1952-1988

Plants 2, 3 and 8 and Surrounding Buildings (33a, 45a)
B00

700

600 +

8

Number of workers

s
s

200

100

1960 1955. 1960 1985 1970 1975 1980 4985 1990
Year


nS

© Naturally occurring decay product of 226Radium,
the fifth daughter of 2%Uranium

© Both 8Uranium and 226Radium are found in most
soils and rocks

© Radon decays with a half-life of 3.82 days into a
series of short-lived radioisotopes that are
collectively referred to as radon daughters, radon

progeny and radon decay products.


Location Assignment Method

ETE |

« Personnel records did not include location,
except for production workers assigned to a Plant

« General personnel records misclassified location
for approximately 1/5 of workers for whom
location could be inferred from the records


Detective Work
=< _|nspection-of CR-39 data_shows-very_highlevels_near__.__

—-.)

plant 2/3, = A )

© Interviews with Fernald HP’s and retired workers
identified a potential source

© Q-11 silos near plant 2/3 had been used to store
highly radioactive material for later processing

© Several other secondary sources were identified in
the same area

© Search of documents reveals that Q-11 silos were
filled from 1952-58




Overall Area Codes for Some Workers

* Some job titles known to work at a variety of
areas throughout plant site

« For other job titles, insufficient information to
assign them to a specific location.

: Developed “area” codes

» Multiple exposure estimation sites linked to each
area, weighted by number of employees, with
specific or combination location assignment,
assigned to that location in that calendar year.


4
od

Events leading to research study

Excess relative risk for jung cancer was found in a mortality
study of workers at the Fernald Feed Materials Plant near
Cincinnnati OH in 1996.

* ACDC dose reconstruction project for estimation of exposures

to residents within 10 km of Fernald indicated relatively high
radon levels off site.

Sources of radon decay products were determined to be two K-
65 silos located on the west side of the plant and used for
storing waste materials including radium.

NIOSH contracted with the University of Cincinnati to estimate
radon exposures and cigarette smoking rates among Fernald
workers for possible follow-up of the lung cancer mortality study.


Exposure Estimation Metho

« Estimate radon exposure at selected site locations
« Specific to calendar year
« Specific to time of day (shift)

K65 exposure + Q11 exposure = Total Radon
Exposure

» Place workers at site locations for each calendar year

* Assign a probability of working day, evening, night or
rotating shift

« Link radon estimates with annual location assignments
for each worker in the cohort






Pitchblende Ore Processin

g

enna

Uranium separated from ore by 3-phase Purex
process: digestion, extraction and denitration

Aqueous raffinate or waste contained all daughter
products from uranium and impurities including
226Radium (the parent nuclide of 222Radon)

Assigned code name K-65

Pumped into large concrete silo for storage (K-65
silo)


__Estimates for Fernald Workers

SSS SESS

Susan M. Pinney, PhD
Department of Environmental Health

: Methods for Radon Exposure
|

| Richard Hornung, DrPH

Institute for Health Policy and Health Services
Research

University of Cincinnati


5072

~————4

[ 7035



Worker Assigned a Combination Code

ID: 37444

1 Hire Date Term Date

: 08/01/1952 01/01/1983

Date Plant Dept Job Title Location Code
08/01/1952 Anal Tech Technologist B ANDBIdg15,P
10/01/1955 Anal = Tech Technologist If ANDBidg15,P
08/27/1956 Anal Tech Section Leader | Bidg15+P
08/21/1959 Anal = Tech Section Leader li Bldg15+P
05/01/1972 Anal = Tech Technologist Ill ANDBidg15,P


}

We understand that in calculating the Fernald workers’ doses, the scientists used DOE
documents only. There was no input from the workers and none of the evidence from the experts
at the Fernald Workers’ trial in federal court was considered. Thus, we maintain that the doses
being calculated (even without consideration of Dr. Pinney’s radon study) are inaccurate.

We also note that Dr. Pinney did not include a dose for thoron, which was also present at
Femald.

Thank you for your consideration of this matter.
If you have any questions, please contact the undersigned.

Sincerely,


Count

3500

3000

2500

2000

1500

1000

500

Distribution of Cumulative Total Radon Exposure (WLM)

from the K-65 Source

14 16 18 20 22 24 26 28 30 32 36
Cumulative K-65 (WLM)

36 38 40 42 44 46 48 51 83 56


Percent Working Each Shift (Salf-Reported) by Standardized Job Title Clustets R-X

7 i (aay
8 Eve Shift
é 1D Night Shift
=| |O Rotating
is cae . Eg ase
fers if ‘ FA
40.0 +:

Aways rotate Security Transportantion Warehouse; Stores Always day - no data
Cluster of Standardized Job Title


Model Results

Polynomial and restricted cubic spline models both fit
log Po-210 data reasonably well (R?2 = 0.50-0.53)

~ 24% | year decrease for later construction years

~ Po-210 levels are 60% less on inside of buildings

Buildings upwind and at a distance from Q-11 silos
were estimated to have exposures one to two orders
of magnitude lower than Q-11 area

~ Po-210 results were used by the study HP to

calculate Rn exposures in WL by year for each bidg


Overall Area Code - Example

« Overall Area Code — ALL

« 30 location components — with exposure
value specific to each calendar year, and
weighting, specific to each year


Radioactive Waste
Shipped to Fernald

Sa aeeeenneenemenetnsnnnananssaaseenoeaaaeeeememeeeeteemeee ee)

Prior to 1953, large amounts of radium bearing
radioactive waste were shipped to FMPC from
other DOE sites, especially Mallinckrodt Chemical
Works in St. Louis (12,997 drums)

Drums stored on a concrete pad near Plant 1 until
K-65 silos were completed

Some drums of K-65 material also stored near
Plant 8 for longer period of time


ew.

Count

180

160

140

120

100

Distribution of Cumulative Non-Zero Radon Exposure (WLM)
from the Q-11 Source

1 51 114 238 481
Cumulative Q-11 (WLM)


Value of FWMMP Occupational History
Questionnaire and Interview Information

SSS = —= Sa = a re — a

——_——=T

« Use of the FWMMP occupational history questionnaire and
interview information allowed us to:

» Much more precisely assign worker location; workers
assigned to multiple buildings rather than a single location

» Assign a probability of having worked the night shift, when
exposures were 2-4 times higher

» Verify and validate our location and shift assignments

Resulted in:
» Wider range of exposures and higher upper bound of the
range

» For compensation: Worker assigned to multiple locations
(each with a different exposure estimate) and shift (separate
matrix for night shift)


Pitchblende Ore Processed at
Fernald from 1952-1958

« Rock containing very high concentrations of
uranium and uranium daughter products
(including radium).

« Received at FMPC from mine in-the Belgian
Congo (Shinkolobwe mine).

«» Code name Q-11; Stored in Q-11 ore silos near
Plant 1